Zietzke
Zietzke v. United States
Opinion
Trial Court Opinion
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 6 WILLIAM ZIETZKE, Case No. 19-cv-03761-HSG (SK)
Plaintiff, AMENDED REPORT AND
RECOMMENDATION REGARDING
v. MOTION FOR SUMMARY DENIAL
OF PETITION TO QUASH AND FOR
UNITED STATES OF AMERICA, ENFORCEMENT OF IRS SUMMONS
Defendant. Regarding Docket No. 10
This matter was referred to the undersigned for a report and recommendation on the motion to enforce a summons and for a summary denial of the petition to quash filed by the Defendant, the United States of America (“Government”). For the reasons set forth below, the Court RECOMMENDS enforcing the summons with some limitations on its scope. BACKGROUND Petitioner William Zietzke (“Petitioner”) filed a petition to quash a summons issued by the Internal Revenue Service (“IRS”) to Coinbase, Inc. (“Coinbase”), a “cryptocurrency” exchange, regarding his federal tax liability for the tax year 2016 (the “Summons”). (Dkt. No. 1.) On…